Skilled nursing facility therapy billings in the Ultra-High RUG category increased steadily in recent years and passed a significant threshold in 2013, according to a government memorandum.

The Ultra-High Rehabilitation category accounted for more than 50% of SNFs' Medicare Part A billed days of service last year, the Centers for Medicare & Medicaid Services has determined. In 2011, the proportion of residents classified in the Ultra-High group was 44.8%, and this rose to 48.6% in 2012.

During these years, use of all other therapy billing categories — Very-High, High, Medium and Low — remained steady or declined, according to the “Observations on Therapy Utilization Trends” memo released by CMS. During an Open Door Forum call Tuesday, CMS officials encouraged providers to review the document. It was issued in conjunction with the proposed SNF Medicare rates for 2015, which were released last week and published in Tuesday's Federal Register.

Analysts also found that the amount of therapy being provided increasingly is “just enough to surpass” therapy minute thresholds, the memo states. This is especially true for the Very-High and Ultra-High categories.

In addition to the memo, these findings are summarized in the proposed rule setting 2015 SNF Medicare rates. The proposed rule explains that there are no policy changes related to these trends, which CMS has tracked since revising therapy billing policies in 2012. However, the agency will continue to monitor billing patterns and might adjust policies accordingly in the future.